Clarke v. District of Columbia

PAIR, Associate Judge:

This appeal is from a judgment entered on a directed verdict in an action against the District of Columbia (the District) for “false arrest, false imprisonment, unlawful search and assault.”

At the commencement of the trial, which was before a jury, the court advised counsel for appellant that she would be limited in her proof to the issue of false arrest because, in the court’s judgment, that was the only issue spelled out in the pretrial order. 1 Counsel for appellant sought leave of court to amend the pretrial order, urging that any deficiencies in the order were the…